City of ST. Louis v. James H. Praprotnik (485 U.S. 112)

U.S. Supreme Court · decided March 2, 1988 · Supreme Court Database (Spaeth)

Citation
485 U.S. 112 · 108 S. Ct. 915
Decided
March 2, 1988
Term
October Term 1987
Vote
7–1
Majority author
Justice O'Connor
Issue area
Civil Rights
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice O’Connor announced the judgment of the Court and delivered an opinion, in which The Chief Justice, Justice White, and Justice Scalia join. This case calls upon us to define the proper legal standard for determining when isolated decisions by municipal officials or employees may expose the municipality itself to liability under 42 U. S. C. § 1983. I The principal facts are not in dispute. Respondent James H. Praprotnik is an architect who began working for petitioner city of St. Louis in 1968. For several years, respondent consistently received favorable evaluations of his job performance, uncommonly quick promotions, and significant increases in salary. By 1980, he was serving in a management-level city planning position at petitioner’s Community Development Agency (CDA). The Director of CDA, Donald Spaid, had instituted a requirement that the agency’s professional employees, including architects, obtain advance approval before taking on private clients. Respondent and other CDA employees objected to the requirement. In April 1980, respondent was suspended for 15 days by CDA’s Director of Urban Design, Charles Kindleberger, for having accepted outside employment without prior approval. Respondent appealed to the city’s Civil Service Commission, a body charged with reviewing employee grievances. Finding the penalty too harsh, the Commission reversed the suspension,…

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